The coming into force of Canada’s Bill C-69 in August 2019 marked, as many would cautiously agree, a significant turning point in how mining projects must approach environmental assessments and related supply chain transparency. It’s not merely about satisfying regulatory requirements on paper; there is now, arguably, a heightened expectation for firms to demonstrate how their operations align with evolving standards for environmental and social responsibility. While the implications of the legislation are still settling across the sector, it is already clear that mining firms must adapt their supply chain disclosure practices—sometimes in ways they hadn’t anticipated. One might even suggest that the industry is only just beginning to grapple with the full breadth of these new obligations.
At the heart of this legislative shift lies the requirement for more rigorous public disclosure of supply chains associated with mining projects. This includes, but is not limited to, the origins of raw materials, the methods of extraction and transport, and the social and environmental impacts across the chain. The level of detail expected has, in some cases, taken project proponents by surprise. Where earlier frameworks might have accepted general outlines, the new process insists on specifics—sometimes down to individual supplier phases. This can feel overwhelming, especially for firms that have traditionally focused their compliance efforts narrowly on site-level impacts. Yet this is where Bill C-69 diverges meaningfully from past practice.
Mining firms are now strongly advised to make full use of open government data platforms to meet these expectations. The Canadian Energy Regulator (CER) portal, for instance, offers an essential starting point for companies mapping out their material-sourcing plans. Through this portal, firms can access guidance and datasets that help identify and document upstream and downstream supply chain components in a manner consistent with the law’s disclosure requirements. It would be difficult to overstate the value of this resource, although there are moments when its complexity, or the sheer volume of data, can present its own challenges. Some firms, in attempting to integrate CER data into their reporting, have found themselves needing additional analytical capacity—something not all companies had budgeted for at the outset of their project planning.
One important development arising from the Act’s new framework is the need for quarterly environmental and social impact disclosures that cover supply-chain phases, not just the activities at the mine site itself. This represents, in a way, a philosophical shift. The idea is to move beyond a narrow focus on the immediate footprint of the mine and instead capture the broader consequences of associated supply chain decisions. It’s an approach that, some might argue, begins to align Canadian mining practices more closely with international norms around responsible sourcing and ethical supply chain management. But it is also, quite plainly, a demanding exercise—especially given the pace at which many projects operate.
In practical terms, companies are encouraged to adopt internal checklists that ensure consistent reporting across these quarterly disclosures. Such checklists would, at a minimum, cover elements like material origins, transportation emissions, community engagement around supplier activities, and any identified risks or incidents linked to third-party providers. There is no one-size-fits-all template for these checklists—nor should there be, perhaps, given the diversity of Canada’s mining sector—but failing to develop one at all could leave a firm exposed to criticism or compliance gaps. Anecdotally, some industry stakeholders have shared that their initial disclosure cycles revealed unanticipated weaknesses in how supply chain data was collected or validated. This is not uncommon, and regulators appear, so far, to have shown some understanding as companies adjust to the new standard.
A recurring observation from firms navigating Bill C-69’s disclosure demands is the importance of cross-functional collaboration. Supply chain managers, environmental compliance teams, legal counsel, and even public relations departments find themselves working more closely together than before. This makes sense. After all, the disclosures required under the new Act do not exist in a vacuum; they inform public perception, investor confidence, and regulatory standing all at once. Yet managing these internal dynamics is itself a complex task, one that firms should not underestimate as they refine their reporting processes. In some cases, organizations have noted that it was only after a few reporting cycles that they identified redundancies—or, conversely, critical gaps—in their internal data flows.
It is worth noting, too, that the legislation’s intent extends beyond compliance. The hope—or at least the policy rationale—is that increased transparency will drive better outcomes for communities and ecosystems affected by mining activities. Whether this plays out as envisioned remains, perhaps, an open question. The alignment of corporate practices with regulatory aspirations is rarely seamless, and here is no exception. Early disclosure reports under the Act suggest that while some firms have embraced the spirit of the law, others are navigating it with a degree of reluctance, focusing more narrowly on the minimum requirements.
What seems clear at this stage is that the firms most likely to thrive under the new framework are those that engage proactively with both the technical and the ethical dimensions of supply chain transparency. This means not just reporting data as required, but using that data to inform decision-making in ways that contribute to more sustainable practices. The CER portal, for all its technical complexity, provides a foundation. But the broader task—the one that will, in time, define industry leaders—lies in how firms choose to integrate this transparency into their operational and strategic priorities.